Subject: File No. S7-25-99
From: Brian Breidenbach, MBA, CPA, CFA

September 10, 2004

I’m am writing regarding the concern I have for stockbrokers ability to call themselves financial planners or advisors. Brokers lack independence and have multiple conflicts-of-interest. The AICPA just released a Fiduciaries Standards Handbook and outlines the lack of independence of stockbrokers.

The SEC needs to prevent stockbrokers from claiming and disguising themselves as “advisors”. How will the consumer know when fee-based products crosses the realm of commission based products. If the SEC is muted on this subject there becomes an implied a level of expertise bestowed by the SEC on stockbrokers.

The SEC needs to step for the consumer and clearly state that stockbrokerage firms are NOT advisors.